IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE The Money Suite Company, Plaintiff, v.

Farmers Group, Inc., Defendant. JURY TRIAL DEMANDED Civil Action No.

COMPLAINT FOR PATENT INFRINGEMENT This is an action for patent infringement in which Plaintiff The Money Suite Company (Money Suite) makes the following allegations against Farmers Group, Inc. (Defendant). PARTIES 1. Money Suite is a Delaware corporation that maintains its principal place of

business at 200 W. Broadway, Suite C, Missoula, Montana 59808. 2. On information and belief, Defendant is a Nevada corporation with its principal

place of business at 4680 Wilshire Blvd, Los Angeles, CA 90010. Defendant has appointed CSC Services of Nevada 2215-B Renaissance Dr., Las Vegas, NV 89119 as its agent for service of process. JURISDICTION AND VENUE 3. This action arises under the patent laws of the United States, 35 U.S.C. 1, et

seq., including 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a). 4. This Court has personal jurisdiction over Defendant because, among other

reasons, Defendant has done and solicited business in this District, has committed acts of patent infringement in this District, and has harmed Money Suite in this District, by, among other

things, using, selling, offering for sale, and importing infringing products and services in this District. 5. Venue is proper in this District under 28 U.S.C. 1391(b)-(d) and 1400(b)

because, among other reasons, Defendant is subject to personal jurisdiction in this District, has transacted business in this District and has committed acts of patent infringement in this District. On information and belief, for example, Defendant has used, sold, offered for sale, and imported infringing products in this District. COUNT I INFRINGEMENT OF U.S. PATENT NO. 6,684,189 6. MoneySuite is the owner as assignee of all rights, title and interest in and under

United States Patent No. 6,684,189 (the 189 patent), which duly and legally issued on January 27, 2004, with Ronald B. Ryan and Ronald G. Marquart as the named inventors, for an apparatus and method using front-end network gateways and search criteria for efficient quoting at a remote location. Attached hereto as Exhibit A. 7. Defendant has directly infringed at least claim 1 of the 189 patent, in this judicial

district and elsewhere in the United States, by, among other things, making, using, importing, offering for sale, and/or selling financial product quotation products and services that fall within the scope of the claims of the 189 patent, including but not necessarily limited to insurance quotation products and services provided at the www.farmers.com website, including, for example, the auto and life insurance quote services on that website. By making, using, importing, offering for sale, and/or selling such products and services which fall within the scope of the 189 patent, including but not limited to using front-end network gateways and selection criteria entered at a remote computer terminal to conduct a search of multiple financial products for efficient quoting at a remote location and all like products and services, Defendants have injured Money Suite and are thus liable for infringement of the 189 patent pursuant to 35 U.S.C. 271.

8. authorization. 9.

Defendant has committed these acts of infringement without license or

As a result of Defendants infringement of the 189 patent, Money Suite has

suffered monetary damages in an amount not yet determined, but in no event less than a reasonable royalty for the use made of the invention by Defendant, together with interest and costs as fixed by the Court. 10. To the extent that facts learned in discovery show that Defendants infringement

of the 189 patent has been willful, Money Suite reserves the right to request such a finding at the time of trial. 11. As a result of Defendants infringement of the 189 patent, Money Suite has

suffered monetary damages and is entitled to a money judgment in an amount adequate to compensate for Defendants infringement, but in no event less than a reasonable royalty for the use made of the invention by Defendant, together with interest and costs as fixed by the Court. 12. This is an exceptional case within the meaning of 35 U.S.C. 285. PRAYER FOR RELIEF Money Suite respectfully requests the following relief: A. That the Court declare that the 189 patent is valid and enforceable and that its

claims have been infringed by Defendant as described herein; B. infringement; C. Suite; D. action; and E. Such other and further relief as the Court deems just and proper. That the Court award to Money Suite its costs and attorneys fees incurred in this That the Court award pre and post judgment interest on the damages to Money That the Court award damages to Money Suite to which it is entitled for patent

DEMAND FOR JURY TRIAL Money Suite, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury on all issues so triable.

June 3, 2013

FARNAN LLP /s/ Brian E. Farnan Brian E. Farnan (Bar No. 4089) 919 North Market Street, 12th Floor Wilmington, Delaware 19801 (302) 777-0300 (302) 777-0301 (Fax) bfarnan@farnanlaw.com

ATTORNEYS FOR PLAINTIFF THE MONEY SUITE COMPANY Of Counsel: Marc A. Fenster Adam S. Hoffman Benjamin T. Wang Michael T. Boardman RUSS, AUGUST & KABAT 12424 Wilshire Boulevard, 12th Floor Los Angeles, CA 90025-1031 (310) 826-7474 mfenster@raklaw.com ahoffman@raklaw.com bwang@raklaw.com mboardman@raklaw.com